Mayor’s Transport Strategy - Public Draft (October 2009)
Mayor of London
Response on behalf of London Borough of Croydon
1. General Comments
1.1 Croydon council welcomes this opportunity to provide our views and comments on the policies and proposals for transport in the capital over the next twenty years as set out in the Mayor’s Public Draft Transport Strategy.
The council also welcomes the simultaneous publication of the draft revised London Plan and Economic Development Strategy, which should ensure that these three important documents are aligned as a means of reducing the need to travel in the first place and to ensure that transport investment and site development are properly integrated.
1.2 The council broadly supports the six overarching goals of the strategy. It also welcomes the increased emphasis in the strategy on improving transport in outer London, along with the setting up of the Outer London Commission (OLC) to look at wider development issues and the role of transport in supporting growth. We also welcome the proposal for sub-regional transport plans to provide more detailed proposals for each sub-region.
1.3 The council notes the policies and proposals of the Mayor’s draft Transport Strategy and the major committed schemes for improving London transport. These will bring benefits to London in which Outer London in general, and Croydon in particular, hope to share. However, Croydon council is concerned at the deliverability of the proposals given the level of funding and delayed programming.
1.4 The council welcomes the strong line the draft strategy takes on sustainability. In general, it supports the whole suite of proposals to increase use of water for freight, to increase access for people with a disability, to reduce carbon emissions and manage freight, bus, rail and tram travel better and to use better systems to increase traffic flow and so reduce emissions.
1.5 The council recognises that ‘Choice’ has to be a key principle of a sound transport strategy for London. Having said that, the Borough does have concerns over the ability to persuade people to leave their cars at home as part of a sustainable strategy and for improving orbital movement for Outer London, beyond the completion of East London Line Extensions 1 & 2, particularly in the light of the decision not to progress work on the Crystal Palace Tram Extension. The Borough welcomes, therefore, the opportunity to continue to work with the Mayor for London and Transport for London (TfL) to explore opportunities for potential tram extensions and to secure improvements to current tram operations and to increase passenger capacity.
1.6 In Outer London, the car is the dominant mode of transport for trips originating there, accounting for 52 per cent of all trips by residents. London-wide, 48 per cent of all trips by residents are solely within Outer London. It is therefore important to improve access to jobs, services and opportunities in order to tackle deprivation and encourage inward investment and local job creation.
Croydon council feels that the strategy does not address this need adequately and believes that local transport services should be prioritised. The MTS needs to set out how this will be achieved.
1.7 The council welcomes the Mayor’s principle of improving the integration of economic development, transport, spatial and land use planning as a means of affecting travel patterns and reducing the need to travel. It follows that the transport policy must also be well integrated and timely with other policy areas such as health, education, and duties under the Traffic Management Act.
It is important therefore that the MTS acknowledges this and links with the specific policies and proposals.
1.8 The council welcomes the renewed emphasis on a “better allocation of surface space between pedestrians, cyclists and motorised modes” together with an improved public realm and hope that TfL will continue to allocate sufficient funds to boroughs to implement high quality integrated schemes to support local trips by sustainable modes.
1.9 London’s population and economy are expected to expand by 1.3 million more people and by over 750,000 more jobs in Greater London by 2031. Croydon council’s regeneration agenda is expected to result, over the next twenty years, in up to 10,000 more households in Croydon Metropolitan town centre alone; a recognised growth area. Supporting the expected economic development and population growth will require local transport infrastructure enhancements which are not adequately addressed in the MTS. Severe congestion issues at East Croydon station appear to have been completely overlooked. Overcrowding and congestion are likely to deteriorate to unacceptable levels and environmental objectives for the reduction of CO2 emissions not be met. Furthermore, policies within the strategy are predominantly supportive of improvements to radial capacity, with little commitment to enhancing orbital movements.
Responses to Specific Transport Proposals
2 . Managing and enhancing the transport system
2.1 Rail
The council welcomes the strategy’s call for greater Mayoral powers over national rail in London, as a borough that is dependent on ‘heavy rail’ for longer public transport journeys and looks forward to greater TfL involvement in and funding for rail station and service improvements in the borough.
i) Although Croydon’s rail lines are not currently within the Mayor’s remit, other than the overground stations along the East London Line extension between West Croydon and Crystal Palace, we have a number of concerns and hope TfL can bring pressure to bear on the TOCs/ Network Rail with regards to these.
ii) Croydon has been officially recognised as an Opportunity Area. Croydon also has an aspiration to be recognised as London’s third city, supported by its growing economic prominence within Greater London. Croydon Council would therefore welcome the opportunity to discuss with the Mayor, through TfL, improved services between South London and the sub-regions as well as the provision of High-Speed Rail services directly available to/from central Croydon and to/from other areas of London apart from Central London and Stratford.
iii) Croydon supports the proposal to seek further rail capacity across London’s rail network, beyond those schemes already committed and also supports the recognition that the issue of congested stations must be addressed. However Croydon is deeply concerned at capacity issues which affect longer-distance services using the Brighton Main Line which are more serious than appears to be generally recognised, due to inherent flaws in Network Rail’s consultation draft Sussex Route Utilisation Strategy where there is:
- No allowance in the RUS for suppressed demand.
- No allowance for the impact of Croydon’s own Town Centre regeneration agenda with proposals for an additional 10,000 housing units and employment growth over the next 20 years.
Croydon therefore believes that serious early consideration is needed for more radical interventions, having regard to the necessary lead time for implementing major infrastructure enhancements.
The council is also concerned that there appears to be a missing link in the prospective regional and sub-regional rail network, in that the West Coast Main Line (WCML) will have no direct Thameslink connection, and the existing inter-regional connection between WCML and Gatwick Airport faces serious capacity issues where it joins the Brighton Main Line immediately South of Clapham Junction.
iv) Croydon supports the proposal to seek station capacity enhancements at some of London’s most congested stations. However, Croydon is deeply concerned that severe congestion issues at East Croydon station appear to have been completely overlooked:
· East Croydon is now, according to the latest ORR data, one of the ten busiest rail destinations in the country (the other nine all being Central London termini), and is clearly a major destination in its own right.
· East Croydon is also, again according to the latest ORR data, the third busiest interchange station in the country, behind only Clapham Junction and London Bridge.
· Croydon’s own Town Centre regeneration agenda will have significant impacts on an already congested system, giving rise to significant adverse impacts including health and safety implications.
· In the short term, network capacity and platform congestion can be improved at East Croydon station by allowing the Gatwick Express trains to stop there. Croydon also requires an early commitment, with an agreed programme, to construct the additional new platform at East Croydon station.
v) Croydon expects work to address the accessibility and capacity issues at West Croydon station to be prioritised. Croydon seeks TfL’s support for West Croydon station works to be prioritised in DfT’s and Network Rail’s investment plans.
2.2 Tramlink
Croydon council welcomes the commitment in investment and maintenance, renewals, upgrades and capacity enhancements planned for Tramlink between now and 2015.
The council also welcomes the statement that consideration will be given to looking at further extensions of Tramlink, with a strong focus on a potential north-south axis, in order to accommodate Croydon’s future growth needs. This however falls short of the aspirations of many Croydon residents who see this extremely efficient, ecologically friendly and highly accessible form of transport as a preferable means of travel to that available to them at present.
We would therefore like to see a stronger commitment than just “consideration be given at further extensions”, recognising the potential to improve east-west links to neighbouring Outer London town centres and its significance in enhancing orbital connectivity.
Given that TfL Business Plan to 2017/18 funds have already been accounted for, it is imperative that tram extension studies are completed and funded in future business plans. Croydon expects to see an explicit commitment that Tramlink extensions will be a top priority for the TfL’s Business Plan after 2017/18.
2.3 Bus network
Croydon council supports the proposal to keep the development of the bus network under regular review to cater for growth in population and employment, maintain ease of use, attractive frequencies and adequate capacity, reliable services, good coverage and good interchange. This is particularly important in outer London boroughs where buses are the only viable and attractive public transport alternative to the private car for medium and longer journeys.
However, the council is greatly concerned at the Mayor’s intension of cutting bus budgets as part of his “efficiency savings” and the effect this will have on implementing his proposals. This will inevitably mean the reduction of bus services/frequencies on an already congested system, with little scope for increasing capacity and network coverage to cater for the projected growth in housing and population growth as well as employment and retail activity in outer London. It is important to ensure that such growth does not lead to an increase in private motor vehicle trips, as well as undermine the ‘suburban character’ of outer London. The strategy must address this major issue.
Bus standing facilities are an important part of enhancing and developing the bus network and as such must also be addressed by the strategy.
The council is also concerned regarding the reliability and fairness of the overall service change consultation process. Local views must play an important role in service provision.
In order to attract more car users onto buses the journey experience must not only be as comfortable and convenient as possible, but also safe. The safety aspect including fear of crime are important considerations which are overlooked. Croydon council run a pilot scheme where night time marshals were used on a limited number of late night services used by visitors to Croydon’s night time economy. Though the scheme was an overwhelming success it was not supported financially beyond the pilot phase. The Mayor should give serious consideration to safety on public transport and finance initiatives which support this.
2.4 Taxis / Minicabs / Community Transport
Croydon council welcomes the Mayor’s support for improvements to the taxi service. Taxis are a safe and quick way of making door-to-door journeys and are particularly valuable for disabled people.
The council also welcomes the Mayor’s commitment to support community transport services and to look at ways to closer coordinate them with transport facilities provided by TfL. However, the strategy makes no mention of dial-a- ride, mobility buses and the taxi-card, which play an important part in transport provision for the mobility impaired and therefore should be addressed.
2.5 Managing the road network
The council supports the principle of ‘smoothing the traffic’ in terms of reducing congestion and stop-start driving as long as this is not at the expense of pedestrian and cycle crossing times or convenience and doesn’t encourage more traffic or speeding. There is also a need for a review of all traffic signal timings to reduce unnecessary delay to traffic and ensure consistency and an equitable balance of priorities between private motor traffic and other modes.
Adequate funding for road and infrastructure improvements is essential in order to reduce ongoing and frequent works on poorly maintained roads which contribute to congestion and impact on reliability of journeys.
Better real time information for drivers about congestion/disruption and planned closures and road works will also assist in advance route planning and traffic congestion reduction.
Targeted physical measures at bottlenecks could also assist in smoothing traffic flows.
2.6 Airports
The strategy states that the Mayor recognises that adequate airport capacity is critical to the competitive position of London in a global economy. However, Croydon council believe there should be a greater emphasis on demand management, reviewing the taxation regime for aircraft fuel, encouraging greater use of high speed rail for short haul journeys and regional airports as opposed to London hubs. There also needs to be a review of rail fares, avoiding pricing which could deter use of rail services which have spare capacity.
Croydon is concerned that the increase of surface access trips likely to be associated with the potential doubling of [unconstrained] air passenger volumes at London’s airports between 2006 (140M) and 2031 (290M) would be potentially catastrophic from both air quality and road congestion standpoints.
Croydon council is seriously concerned at the loss in December 2008 of Gatwick’s only direct inter-regional rail service, and the further loss in September 2009 of direct and reasonably frequent regional rail services between Gatwick Airport and Watford. Watford is served by the West Coast Main Line, which itself serves a very large customer base in the Midlands and northwest England but has no direct Thameslink connection. Many users of the discontinued rail services, while possibly neither living nor working in London, now have no practical choice but to: